National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2296
Submission to the Senate Community Affairs Legislation Committee
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
Request: Name withheld, submission published
Dear Committee Members,
I am a speech pathologist operating a small rural allied health practice servicing MMM4 and MMM5 communities in north-west Victoria.
I support efforts to ensure the long-term sustainability of the National Disability Insurance Scheme (NDIS). However, I am concerned that aspects of the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 may unintentionally reduce participant choice and control, create additional barriers for small providers, and worsen service accessibility in rural and regional communities.
My concerns are outlined below.
- Increased Barriers for Small and Rural Providers
The proposed reforms appear likely to increase regulatory requirements, compliance obligations and administrative oversight for providers delivering supports under the NDIS.
While larger organisations may have the resources and administrative teams necessary to absorb these changes, many small providers operate with limited staffing and administrative support. For sole practitioners and small businesses, increased compliance requirements can significantly reduce the time available for direct participant services and increase the cost of service delivery.
Rural communities already face substantial challenges in attracting and retaining allied health professionals. Additional administrative burden may discourage providers from continuing to offer services under the NDIS, further reducing participant choice and access to supports.
I am also concerned about the potential implications of future programs such as Thriving Kids if Victoria adopts a service delivery model similar to that implemented in New South Wales, where service delivery has been directed through selected organisations.
Should Victoria adopt a similar approach that limits participation by appropriately qualified private allied health providers, there is a risk of significant unintended consequences for the existing allied health workforce.
Across Australia, many private allied health clinics have invested substantial personal and financial resources into establishing services that support children and families. These investments include clinic establishment costs, professional registration, insurance, assessment tools, therapy resources, staffing, ongoing professional development, vehicles, technology and compliance systems.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2296
Providers have made these investments in good faith based on existing policy settings and the expectation that appropriately qualified providers would continue to have opportunities to deliver services to their communities.
If future referral pathways are restricted to selected organisations or provider types, many private clinics may experience a significant reduction in referrals and revenue despite continuing community demand for their services. In some circumstances, this may place the viability of small businesses at risk.
This concern is particularly relevant in MMM4 and MMM5 communities, where providers often operate with limited margins and where alternative referral pathways may be scarce. Providers who have invested heavily to establish services in areas experiencing longstanding workforce shortages may find it difficult to maintain viable businesses if excluded from major government-funded programs.
The closure of private practices, or reductions in service capacity, would not only affect providers but could also reduce participant choice, increase waiting times and limit access to local services for children and families.
Any future commissioning, tendering or referral processes should ensure that appropriately qualified private providers are able to participate on an equitable basis alongside NGOs and not-for- profit organisations. Participation should be determined by qualifications, experience, service quality and community need rather than organisational structure alone.
I urge the Committee to consider the disproportionate impact that increased compliance requirements and potential exclusion from future programs may have on sole practitioners and small businesses operating in regional and rural communities. Protecting the sustainability of these providers is essential to maintaining service capacity and participant choice across rural Australia.
- Reduced Participant Choice and Control
The NDIS was established on the principle that participants should have genuine choice and control over the supports they receive.
I am concerned that aspects of the proposed reforms may reduce participants’ ability to choose providers that best meet their needs.
In many rural communities, participants already have access to only a small number of providers. If providers are unable to continue operating under the proposed arrangements, participants may be left with limited local options and may be required to travel significant distances, rely on telehealth when inappropriate, or experience delays in accessing supports.
Participant choice and control may also be affected if future programs such as Thriving Kids restrict access to services based on provider type rather than participant preference, provider qualifications or service quality.
Families often develop trusted relationships with allied health providers who understand their child’s needs, goals and circumstances. These relationships are built over time and are particularly important for children requiring ongoing intervention and support. If referral pathways or funding arrangements limit access to certain provider types, families may lose the ability to continue
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2296
working with providers they have specifically chosen and with whom they have established therapeutic relationships.
In rural and regional communities, this issue is particularly significant. The number of available providers is already limited, and participants may not have realistic alternatives if local private providers are excluded from future programs. This could result in reduced service choice, increased travel requirements, longer waiting periods and disruptions to continuity of care.
I am concerned that if Victoria adopts a service delivery model similar to that implemented in New South Wales for Thriving Kids, participants and families may lose the ability to choose from the full range of appropriately qualified providers available within their community. While the final Victorian model has not yet been announced, any approach that restricts participation based on organisational structure rather than qualifications, experience and service quality risks undermining the principles of participant choice and control.
The principles of participant choice and control should remain central to any future reforms or service delivery models. Participants and families should be able to access appropriately qualified providers based on their individual needs and preferences rather than being restricted by organisational structure, commissioning arrangements or provider category.
For participants living in MMM4 and MMM5 communities, preserving access to local providers is particularly important. Any reduction in provider choice may have a far greater impact in rural areas than in metropolitan centres where alternative service options are more readily available.
- Impact on Small Providers and Future Programs Such as Thriving Kids
Many small allied health providers have invested considerable personal and financial resources into establishing and maintaining businesses specifically to support NDIS participants and children with developmental needs.
These investments include clinic establishment costs, professional registration, insurance, assessment tools, therapy resources, office facilities, vehicles, technology, ongoing professional development, compliance systems and business operating expenses. Many providers have also accepted the financial risks associated with establishing services in regional and rural communities where workforce shortages have existed for many years.
Providers have made these investments in good faith based on existing government policy settings and the expectation that appropriately qualified providers would continue to have opportunities to deliver services to children and families requiring support.
I am concerned that arrangements which may exclude or disadvantage existing private providers from participating in programs such as Thriving Kids effectively move the goalposts after significant investments have already been made.
While the final Victorian Thriving Kids model has not yet been announced, there remains considerable uncertainty regarding whether private allied health providers will have equitable access to referral pathways, funding opportunities and service delivery arrangements.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2296
Should Victoria adopt a model similar to that implemented in New South Wales, where service delivery is directed through selected organisations, there is a risk of significant unintended consequences for the existing allied health workforce.
Across Australia, thousands of private allied health clinics currently provide speech pathology, occupational therapy, physiotherapy and psychology services to children and families. Many of these practices have invested substantial resources in building service capacity, employing staff, purchasing equipment and establishing services in communities where demand for support remains high.
If future referral pathways are restricted to selected organisations or provider types, many private clinics may experience a significant reduction in referrals and revenue despite continuing community need for their services. In some circumstances, this may place the viability of small businesses at risk.
This concern is particularly relevant in MMM4 and MMM5 communities, where providers often operate with limited margins and where alternative referral pathways may be scarce. Providers who have invested heavily to establish services in areas experiencing longstanding workforce shortages may find it difficult to maintain viable businesses if excluded from major government-funded programs.
The consequences of this would extend beyond individual businesses. The closure of private practices, reductions in staffing, or reductions in service capacity would likely result in fewer service options for children and families, increased waiting times and reduced access to local allied health supports.
Such an outcome would be contrary to the objectives of improving early intervention access and strengthening support for children and families.
Any transition to new funding arrangements should ensure that appropriately qualified private providers are able to participate on an equitable basis alongside NGOs and not-for-profit organisations. Participation should be determined by qualifications, experience, service quality and community need rather than organisational structure alone.
Failure to do so risks undermining existing service capacity, discouraging future investment in rural and regional allied health services, and reducing access to supports for the very children and families these reforms seek to assist.
I encourage the Committee to recommend that any future Thriving Kids arrangements preserve participant choice, maintain workforce capacity and provide equitable opportunities for appropriately qualified private providers, NGOs and not-for-profit organisations to deliver services within their communities.
- Impact on Rural and Regional Communities (MMM4 and MMM5)
The concerns outlined above are amplified in rural and regional communities, particularly within MMM4 and MMM5 locations where access to allied health services is already significantly constrained.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2296
Many rural communities experience:
• Limited availability of allied health providers. • Difficulty attracting and retaining qualified professionals. • Long waiting periods for assessment and intervention services. • Increased travel requirements for participants and families. • Reduced access to specialist services compared with metropolitan areas. • Limited provider choice when compared with larger regional and metropolitan centres. As a result, any reforms that inadvertently reduce the number of providers operating in these communities are likely to have a disproportionate impact on participants living in rural and regional Australia.
Unlike metropolitan areas, where families may have access to multiple providers and service options, participants in MMM4 and MMM5 communities often rely on a small number of local providers to meet their needs. If these providers reduce services, withdraw from programs, or are excluded from future referral pathways, participants may have few or no practical alternatives available.
This issue is particularly relevant in the context of future programs such as Thriving Kids. If service delivery arrangements limit participation by existing private providers, the consequences in rural communities may be far more significant than in metropolitan areas. In some locations, private providers may represent a substantial proportion of the available allied health workforce.
Any reduction in service capacity may result in:
• Longer waiting times for assessment and intervention. • Reduced continuity of care for children and families. • Increased travel burden for participants. • Greater reliance on telehealth where face-to-face services may be more appropriate. • Reduced provider choice and flexibility for families. • Increased pressure on already stretched health, education and disability services. There is also a risk that policies designed for metropolitan service systems may not adequately reflect the realities of rural service delivery. The challenges faced by providers and participants in MMM4 and MMM5 communities are often fundamentally different from those experienced in major cities.
I encourage the Committee to ensure that any reforms, commissioning arrangements or future service delivery models are assessed through a rural access lens and consider the potential impact on workforce sustainability, participant choice and service availability in regional communities.
Protecting and strengthening the existing rural allied health workforce should be a priority. Participants living in MMM4 and MMM5 communities should not experience reduced access to services or fewer provider options as an unintended consequence of reforms intended to improve the disability support system.
The Committee should carefully consider whether the proposed changes provide sufficient safeguards to ensure that participants in rural and regional Australia continue to have access to timely, local and high-quality allied health supports.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2296
- Need for Clear Transitional Arrangements, Consultation and protection of Existing Service Capacity
There remains considerable uncertainty among providers regarding how several aspects of the proposed reforms and future programs will operate in practice.
This uncertainty is particularly concerning for small providers who must make long-term business decisions regarding staffing, service expansion, professional development, equipment purchases, lease commitments and investment in local service delivery. Many providers have established services and built capacity based on existing policy settings and the expectation that appropriately qualified providers would continue to play a role in supporting children, families and NDIS participants.
The lack of clarity surrounding future programs such as Thriving Kids has created significant concern across the allied health sector, particularly in rural and regional areas where providers have often invested heavily to address longstanding service gaps.
Meaningful consultation with private providers, NGOs, not-for-profit organisations, participants and families is essential before implementing major changes that may affect service delivery arrangements, referral pathways or funding models.
In particular, I encourage the Government to ensure that any future reforms:
• Preserve participant choice and control. • Recognise the important contribution of private providers alongside NGOs and not-for- profit organisations. • Ensure equitable participation opportunities for appropriately qualified providers regardless of organisational structure. • Protect existing service capacity within rural and regional communities. • Consider the unique challenges faced by sole practitioners and small businesses. • Minimise unnecessary administrative and compliance burden. • Maintain continuity of care for children, families and NDIS participants. • Support workforce sustainability across the allied health sector. • Avoid unintended consequences that may reduce access to services in MMM4 and MMM5 communities. • Provide sufficient transition periods to allow providers, participants and families to adapt to new arrangements. I am particularly concerned that reforms introduced without adequate consultation or transition planning may inadvertently destabilise existing service networks that communities currently rely upon. Once a provider reduces services, relocates, or closes a practice, rebuilding workforce capacity in rural areas can be extremely difficult.
For this reason, the Committee should carefully consider the potential impact of proposed reforms on the long-term sustainability of existing allied health services, particularly in regional and rural Australia.
Future policy settings should seek to strengthen and expand service capacity rather than create circumstances that may discourage investment, reduce provider participation or limit access to supports for children, families and NDIS participants.
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2296
Clear communication, genuine consultation and equitable implementation processes will be essential to ensuring that reforms achieve their intended objectives without creating unintended barriers for participants or providers.
I respectfully request that the Committee recommend ongoing engagement with rural providers, participants and families throughout the design and implementation of future reforms to ensure that service accessibility, participant choice and workforce sustainability remain central considerations.
Conclusion
There remains considerable uncertainty among providers regarding how several aspects of the proposed reforms and future programs will operate in practice.
This uncertainty is particularly concerning for small providers who must make long-term business decisions regarding staffing, service expansion, professional development, equipment purchases, lease commitments and investment in local service delivery. Many providers have established services and built capacity based on existing policy settings and the expectation that appropriately qualified providers would continue to play a role in supporting children, families and NDIS participants.
The lack of clarity surrounding future programs such as Thriving Kids has created significant concern across the allied health sector, particularly in rural and regional areas where providers have often invested heavily to address longstanding service gaps.
Meaningful consultation with private providers, NGOs, not-for-profit organisations, participants and families is essential before implementing major changes that may affect service delivery arrangements, referral pathways or funding models.
In particular, I encourage the Government to ensure that any future reforms:
• Preserve participant choice and control. • Recognise the important contribution of private providers alongside NGOs and not-for- profit organisations. • Ensure equitable participation opportunities for appropriately qualified providers regardless of organisational structure. • Protect existing service capacity within rural and regional communities. • Consider the unique challenges faced by sole practitioners and small businesses. • Minimise unnecessary administrative and compliance burden. • Maintain continuity of care for children, families and NDIS participants. • Support workforce sustainability across the allied health sector. • Avoid unintended consequences that may reduce access to services in MMM4 and MMM5 communities. • Provide sufficient transition periods to allow providers, participants and families to adapt to new arrangements.
I am particularly concerned that reforms introduced without adequate consultation or transition planning may inadvertently destabilise existing service networks that communities currently rely
National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 2296
upon. Once a provider reduces services, relocates, or closes a practice, rebuilding workforce capacity in rural areas can be extremely difficult.
For this reason, the Committee should carefully consider the potential impact of proposed reforms on the long-term sustainability of existing allied health services, particularly in regional and rural Australia.
Future policy settings should seek to strengthen and expand service capacity rather than create circumstances that may discourage investment, reduce provider participation or limit access to supports for children, families and NDIS participants.
Clear communication, genuine consultation and equitable implementation processes will be essential to ensuring that reforms achieve their intended objectives without creating unintended barriers for participants or providers.
I respectfully request that the Committee recommend ongoing engagement with rural providers, participants and families throughout the design and implementation of future reforms to ensure that service accessibility, participant choice and workforce sustainability remain central considerations.
Thank you for considering this submission.
Submitted by a speech pathologist servicing MMM4 and MMM5 communities in north-west Victoria.